ML20100K519
| ML20100K519 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/07/1984 |
| From: | Hufham J TENNESSEE VALLEY AUTHORITY |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR GL-81-07, GL-81-7, NUDOCS 8412110158 | |
| Download: ML20100K519 (10) | |
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G TENNESSEE VALLEY AUTHORITY -
. CHATTANOOGA TENNESSEE 374ol L.400 Chestnut. Street Tower II '
i December 7,1984
- Director of Nuclear Reactor Regulation Attetton:
Ms. E. Adansas, Chief Licensing Branch No. 4 Division of Licensing U.S.-Nuclear Regulatory Commission' Washington, D.C.
20555 ~
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Dear Ms. Adansas:
' In the Mattier. of
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Docket Nos. 50 -327.
-Tennessee Valley Authority
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50 -328
References:
-1.
D. G. Eisenhut's letter dated December 22, 1980
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regarding NUREG-0612, Control of Heavy Loads at Nuclear Plants..
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[2.
'D. G." Eisenhut's letter dated February 3,1981 J',
~ regarding Conteol of Heavy Loads (Generic. Letter 81-07).
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TVA's msponse to Section 2.1 of Enclosure 3 to mferences 1 and 2 was
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submitted.to you 'for. our Sequoyah Nuclear Plant by L. M. Mills' March 1, 1982 letter. A draft technical evaluation report (TER) on the control of hekyy loads for our Sequoyah Nuclear Plant was transmLtted to TVA by your June 30, 198 2 letter to H. G. Parris.- A subsequent telephone
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conversation was held with NRC staff members on December 3,1982 to-discuss TVA consients on the -draft TER. A supplemental response, which provided addit!.onal information and commitments, as'mquested by the NRC in the
. DeceaNr 3,1982 telephone conversation was submitted on February 25, 1983 As mquested by-your June 30, 1982 letter to H. G. Parris, additional comments to guidelines Sa, Ta, and 7b'were provided to you by the February 28, 1984 letter from L. M. Mills. provides an additional response to guideline 4 of the NRC TER regarding special lifting devices.. Enclosure 2 provides a revision to footnote 1 for guideline 7a.
8412110158 841207 fDRADOCK 05000327 PDR Vg.
k An Equal Opportunity Employer
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. : Director of Nuclear Reactor Regulation December 7,1984 If you have any questions concerning this matter, please get in touch with Jerry Wills at FTS 858-2683 Very truly yours, TENNESSEE VALLEY AUTHORITY I
W. Ntthan, Manager L censi a v1 Regulations Sworn to and subscri before me
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this 7 _ day of.
4-1984
(
lluhl Nob ry Public p
My Connission Expireso' kb". Nuclear Regulatory Connaission (Enclosure)
Region II Attn:
Mr. James P. O'Reilly Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
G S
ENCLOSURE 1-RESPONSE TO GUIDELINE 4 OF THE TECHNICAL EVALUATION. REPORT (TER)
C5257-449 - NUREG-0612 - WESTINGHOUSE NSSS LIFTING DEVICES h
Spenini Lifting Deviess (Guidelina 4, NUREG-0612. Sectien 5 1.1(t))
The following table outlines the reactor vessel head and internals
' lift rigs' compliance with the criteria of ANSI N14.6-1978 as specified by the NRC in section 2.1.5 of the Sequoyah Draft Technical Evaluation Report (TER) C5257-449. These are NSSS devices supplied by the Westinghouse Electric Corporation under contract 68C60-91934. The information supplied in the table was extracted from the Westinghouse report concerning the compliance of these devices with NUREG-0612.
Unless specifically identified, all comments in the table address both rigs.
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q c.f Rssponse to Guidalina 4 'of TER C5257-449
' NA 1Not cpplicabid)
- E. - Equivalency l C:. - Compliance R
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N Noncompliance;
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--1978-Specific TVA's Section P_osition Corrective Action or Equivalency:
3.1.1 E
(a) No design specification was written; however both1 assembly 'and, detailed
manufacturing drawings and purchasing documents do'specify material,. fabrication.q" '..
and testing mquirements.
C (b) There are no adverse environmental conditions which affect the design cr use of-the device. The rurmal operating conditions are 1200F maximum and 500F. minimum.
temperatum at atmospheric pressure.
E (c) Since these special lifting devices cannot be used for' any lift other than their -
intended use and since th'e use of these devices is administrative 1y controlled int Maintenance Instructions MI-1.2,. MI-1.4, and MI-6.22, there is no need for -
nameplate information.
3.1.2 C
A critical items list was submitted in appendix A of attachment A of.the Westinghouse report.
3.1.3 C
A stress mport, signed and verified by a registered professional engineer, was submitted in appendix A of attachment B of the Westinghouse report.
3 1.4 E
Should. any repair. of these lifting devices be required in. the future, a repair l procedum will' be pmpamd at that time to address that particular repair.1The method of repair will be in accordance with the recommendations made by Westinghouse Electric Corporation in WCAP-10346, Evaluation of the' Acceptability of the Reactor Vessel Head Lift Rig, Reactor Vessel Intemals-Lift Rig, Load Cell, :and Load Cell Linkage to the Requirements of NUREG-0612 for Tennessee. Valley Authority,'
Sequoyah No. 1 and No. 2.
3 2.1 N
(a) Although items 3 and 12 of the internals lifting rig cannot be verirled to ' comply.
with ANSI. N14.6, requirements of section 3 2.1 using documentation provided by Westinghouse, the Failum Evaluation provided with Nonconformance Report SQN MEB
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NA -' NotipplicahN)
R:;spsnse to Guid; lina 4 cf TER C5257-449 E - Equiv21ency C - Compliance N - Noncompliance ANSI N14.6
-1978-Specific TVA's Corrective Action or Equivalency Section Position 8406 acknowledges that the rig is " Acceptable for all modes of operation and design-conditions." Additionally, the intemals lifting rig was designed to hardle the Since lower internals uhich weigh approximately 1-1/2 times the upper internals.
all the fuel is removed when.the lower intemals are lifted, only the lift of the upper internals is governed by the requirements of NUREG-0612. The inspection requirements delineated in the July 27, 1984 letter to you from L. M. Mills will assure continued acceptability of this lifting rig.
E (b) Item 1 of the RV head lift rig and items 4, 5, 6, and 27 of the internals lifting rig were listed as having no anterial certification by which to determine fracture toughness. Data obtained from hardness test performed on item 1 of the head lifting rig will be nnalyzed to determine fracture toughness charac teristics. The continued use of the internals lifting rig is justified on the basis of discussion in section 3 2.1(a) above. Hardness tests similar to that.
performed on the head lifting rig will be performed on the internals lifting rig before the completion of the first inservice inspection to confirm material properties.
Refer to section 3.2.1 for equivalency of pins, links, and adapters, etc.
3 2.4 E
3 2.5 NA No wire rope slings are used for both lifting devices.
Neither the drop weight nor the Charpy impact test can be performed since there is 3 2.6 E
no heat number traceability. However, the recommended 125-percent cold proof test is also not feasible. The discussion in section 3 2.1 of this msponse along with the consideration that Westinghouse stated in WCAP-10346 that all material selection was based on its fracture toughness characteristics should be considered as an equivalency to the requirements of this section.
NA - Not cpplidabla '
a Response to Guid: lina 4 cf TER C5257-449 E - Equivrlenzy C - Complirnc2 N - - Noncompliance ANSI N14.6
-1978-Specific TVA's Corrective Action or Equivalency Section Position 331 E
(a) No specific design considerations were required concerning the operating environment. However, both devices were properly coated and lubricated in j
accordance with section 3.6 of_ ANSI N14.6 to reduce the possibility of failure to critical areas due to corrosion or contamination.
NA (b) Galling is of no concern for either lifting device, since there' are basically to moving parts or severe metal to metal contact areas to produce a galling effect.
Additionally, all critical joint connections on these devices are lubricated.
C (c) Westinghouse reports that the sling block, item 3, for the RV head lift rig and item 11 for the RV internals lift rig are the only items that need to be considered for lamellar tearing. Designing to extremely low stress levels and requiring non estructive testing of the base material and assembly welds.at fabrication has satisfied these requirements.
Both devices were designed using wide joint connections with relatively low 3.3.4 C
tolerances which ensures even load distributions of pins and plates.
Cotterpins and lock pins are used to prevent load carrying componets from becoming 3.3.5 C
inadvertently disengaged.
Them are to mmote mechanians for mgagement or disengagement used with either I
3 3.6 NA device.
All critical load carrying members require letters of compliance to ensum material 4.13 C
certification.
Both devices wem designed to standard fabrication practices with a final 4.1.4 C
inspection that includet visual, dimensiorni, procedural, cleanliness, personnel qualification, etc. Additionally, an issuance of a quality release statement that verifles that these devices wem built to the drawing requirements was submitted.
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Rerponse to Guid: lina 4 cf TER C5257-449 NA - Not tpplicablo
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- Equivalency C :-- Compliance s
~ N - Noncompliance
-1978-Specific TVA's Section Position Corrective Action or Equivalency 4.1.5 E
All welding was performed by qualified welders and' weld procedures were -written inL accordance with ASME Boiler and Pressure. Vessel Code,Section IX for Carbon Steel Welds.
4.1.6 E
A formal quality assurance program was.not mquired taring the manufactum of:
either device; however,.all manufacturer welding precedums ard nondestructive:
testing procedures vem reviewed-by Westinghouse prior to use.. Issuance of-a
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quality mlease to ensum conformance with drawing mquirments was performed.
4.1.7 C
All critical load carrying members mquire letters of compliance to ensure material certification...
4.1.9 C
Issuance of quality mleases to ensum conformance of fabrication drawings' was performed by Westinghouse..
q 5.1.3 E
Method of periodic inspection was provided to. NRC by letter' dated. July '27,' 1984 from L. M. Mills to E. Adensam.
5.1.4 E
The use of these special lifting devices am governed by Maintenance Instruetion MI-1.2.
5.1.5 E
These devices have not been individually marked; however, they cannot be used.
for any lift other than the. lift they wem designed for as pmscribed in-SQ-HI-1.2.
5.1.6 E
SQ-MI-1.2 provides an effective history of all lifts using these" devices.
NA - Not"cpplidablo,.
Response to Guid: lina 4 cf TER CS257-449 E - Equivalency C - Complianca N - Noncompliance-ANSI N14.6
-1978-Specific TVA's Corrective Action or Equivalency Sectiert Position The Westinghouse Site Assembly Instruction manuEl required that the' rig suspend 5.2.1 E
100-percent of its rated load for 1/2 hour. During this time, the rig was _ visually inspected, the the load was removed and nondestructive surface examination was performed (either magnetic particle or. liquid peetrant).
Replacement parts that are critical to handling the load will be proof tested,in-5.2.2 C
accordance with ANSI N14.6-1978.
The method by which:Sequoyah will perform periodic inspections was provided 5.3 to. the NRC by. letter dated July 27, 1984 from L. M. Mills to E. Adensam.
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ENCLOSURE 2 t...-
REVISED RESPONSE TO GUIDELINE 7a FOOTNOTES
- 1.
Noncompliance - Section 1.7 of QiAA-70 rqquires' load carrying parts to be designed not to exceed 20 percent of the ultimate strength of the mterial. The lower load block sheave pin, bridge truck pin, bridge saddle pin, and main drum shaft meet the design requirements, but the mterials specified cannot be verified.
Since all pins or shafts are accessible without disassembly, a field Brinell hardness test is recomended in crder to be able to determine the material properties throughout the pin.
2.
Equivalent - Section 3.2 of CMAA-70 requires the crane to be designed and fabricated to the standards of The American Welding Society Manual AWS D14.1-70, " Specification for Welding Industrial and Mill Cranes." 'Ihe procurement specification for this crane
-requires the design for structural members and their connections be in accordance with the applicable parts of AWS D2.0-69, " Welded Highway and Railway Bridges." Additiornlly, the fabrication of all structural steel shall be in accordance with section 1.23, part I of the AISC " Specification for Design, Fabrication, and Erection of Structural Steel for Buildings." These two specifications are equivalent to the requirements set forth in AWS D14.1.
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